ML110260166
| ML110260166 | |
| Person / Time | |
|---|---|
| Site: | 05000021 |
| Issue date: | 12/28/2010 |
| From: | Ogata Y Mitsubishi Heavy Industries, Ltd |
| To: | Ciocco J Document Control Desk, Office of New Reactors |
| References | |
| UAP-HF-10354 | |
| Download: ML110260166 (5) | |
Text
Ak MITSUBISHI HEAVY INDUSTRIES, LTD.
16-5, KONAN 2-CHOME, MINATO-KU TOKYO, JAPAN December 28, 2010 Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Attention: Mr. Jeffery A. Ciocco Docket No.52-021 MHI Ref: UAP-HF-10354
Subject:
Transmittal of Technical Report MUAP-09011 Revision 2 "Summary of Stress Analysis Results for the US-APWR Reactor Coolant Loop Branch Piping"
Reference:
- 1) Letter MHI Ref. UAP-HF-09139 from 'Y. Ogata ("MHI") to U.S. NRC, "Transmittal of the Summary of Stress Reports for the US-APWR Piping Systems and Components" dated on March 31, 2009 With this letter, Mitsubishi Heavy Industries, Ltd. ("MHI") transmits to the U.S. Nuclear Regulatory Commission ("NRC") its technical reports which provide "Summary of Stress Analysis Results for the US-APWR Reactor Coolant Loop Branch Piping, MUAP-09011 Revision 2". Submittal of the enclosed technical reports was one of the commitments in Reference 1.
A previously provided Technical Report, MUAP-09011 Revision 1 entitled "Summary of Stress Analysis Results for the US-APWR Reactor Coolant Loop Branch Piping" has been corrected the inconsistency of contents. Enclosed Technical Report MUAP-09011 Revision 2 is a revised version to incorporate the stress analysis results as described in Reference 1.
As indicated in the enclosed materials, these documents contain information that MHI considers proprietary, and therefore the report should be withheld from disclosure pursuant to 10 C.F.R. § 2.390 (a)(4) as trade secrets and commercial or financial information which is privileged or confidential. Accordingly, the technical reports are being submitted in two versions, on separate compact discs. One version (in CD 1 of Enclosure 2) contains the complete proprietary version of the technical reports. A non-proprietary version of the technical reports is enclosed on CD 2 (Enclosure 3). In the non-proprietary version, the proprietary information, bracketed in the proprietary version, is replaced by the designation
"[ ]". In accordance with the NRC submittal procedures, this letter includes an Affidavit (Enclosure 1) that identifies the reasons why the proprietary version of the Report should be withheld from disclosure pursuant to 10 C.F.R. § 2.390 (a)(4).
Sincerely, Yoshiki Ogata, General Manager- APWR Promoting Department Mitsubishi Heavy Industries, LTD.
Enclosures:
- 1. Affidavit of Atsushi Kumaki
- 2. CD 1: Technical Report, MUAP-09011-P Revision 2, "Summary of Stress Analysis Results for the US-APWR Reactor Coolant Loop Branch Piping (Proprietary)"
- 3. CD 2: Technical Report, MUAP-09011-NP Revision 2 "Summary of Stress Analysis Results for the US-APWR Reactor Coolant Loop Branch Piping (Non-Proprietary)"
The file contained in each CD is listed in Attachments 1 hereto.
CC: J. A. Ciocco C. K. Paulson Contact Information C. Keith Paulson, Senior Technical Manager Mitsubishi Nuclear Energy Systems, Inc.
300 Oxford Drive, Suite 301 Monroeville, PA 15146 E-mail: ck paulson@mnes-us.com Telephone: (412) 373-6466
Enclosure 1 Docket No.52-021 MHI Ref: UAP-HF-10354 MITSUBISHI HEAVY INDUSTRIES, LTD.
AFFIDAVIT I, Atsushi Kumaki, state as follows:
- 1. I am Group Manager, Licensing Promoting Group in Promoting Department, of Mitsubishi Heavy Industries, LTD ("MHI"), and have been delegated the function of reviewing MHI's US-APWR documentation to determine whether it contains information that should be withheld from public disclosure pursuant to 10 C.F.R. § 2.390 (a)(4) as trade secrets and commercial or financial information which is privileged or confidential.
- 2. In accordance with my responsibilities, I have reviewed the enclosed documents listed in Attachment 1, and have determined that portions of the document contain proprietary information that should be withheld from public disclosure. Those pages containing proprietary information are identified with the label "Proprietary" on the top of the page and the proprietary information has been bracketed with an open and closed bracket as shown here "[ ]". The first page of the document indicates-that all information identified as "Proprietary" should be withheld from public disclosure pursuant to 10 C.F.R. § 2.390 (a)(4).
- 3. The information identified as proprietary in the enclosed documents have in the past been, and will continue to be, held in confidence by MHI and its disclosure outside the company is limited to regulatory bodies, customers and potential customers, and their agents, suppliers, and licensees, and others with a legitimate need for the information, and is always subject to suitable measures to protect it from unauthorized use or disclosure.
- 4. The basis for holding the referenced information confidential is that it describes the unique design of the stress analysis results related to the US-APWR piping systems and components, developed by MHI and not used in the exact form by any of MHI's competitors. This information was developed at significant cost to MHI, since it required the performance of research and development and the performance of detailed hardware design and software development extending over several years.
- 5. The referenced information is being furnished to the Nuclear Regulatory Commission
("NRC") in confidence and solely for the purpose of information to the NRC staff.
- 6. The referenced information is not available in public sources and could not be gathered readily from other publicly available information. Other than through the provisions in paragraph 3 above, MHI knows of no way the information could be lawfully acquired by organizations or individuals outside of MHI.
- 7. Public disclosure of the referenced information would assist competitors of MHI in their design of new nuclear power plants without incurring the costs or risks associated with the design of the subject systems. Therefore, disclosure of the information contained in
the referenced document would have the following negative impacts on the competitive position of MHI in the U.S. nuclear plant market:
A. Loss of competitive advantage due to the costs associated with development of the unique plant design of the stress analysis. Providing public access to such information permits competitors to duplicate or mimic the methodology without incurring the associated costs.
B. Loss of competitive advantage of the US-APWR created by benefits of enhanced plant safety, and reduced operation and maintenance costs..
I declare under penalty of perjury that the foregoing affidavit and the matters stated therein are true and correct to the best of my knowledge, information and belief.
Executed on this 2 8 th day of December, 2010.
Atsushi Kumaki, General Manager- APWR Promoting Department Mitsubishi Heavy Industries, LTD.
Docket No.52-021 MHI Ref: UAP-HF-10354 ATTACHMENT I FILES CONTAINED IN CDs CD 1: Technical Report, MUAP-09011-P Revision 2, "Summary of Stress Analysis Results for the US-APWR Reactor Coolant Loop Branch Piping (Proprietary)"
Contents of CD File Name Size Sensitivity Level MUAP-09011-PR2_ Stress Analysis(RCL Branch Piping).pdf 9,295KB Proprietary CD 2: Technical Report, MUAP-09011-NP Revision 2, "Summary of Stress Analysis Results for the US-APWR Reactor Coolant Loop Branch Piping (Non-Proprietary)"
Contents of CD File Name Size Sensitivity Level MUAP-0901 1-NPR2_ Stress Analysis(RCL Branch Piping).pdf 2,355KB Mon-Proprietary